The country of origin of wheel hub units

N351627 August 13, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Edward Hayes Leake and Andersson 1100 Poydras St. Suite 1700 New Orleans, LA 70112 RE: The country of origin of wheel hub units Dear Mr. Hayes: In your letter dated July 23, 2025, you requested a country of origin ruling on wheel hub units, which you filed on behalf of EBI Transmission System (Thailand) Co., Ltd. The articles under consideration are double flanged wheel hub units with tapered roller bearings (wheel hubs), Part Numbers EBH3240 - MOOG: 515096, EBH3241 - MOOG: 515097, and EBH3239 - MOOG: 515058, which are used in passenger vehicles, and light and heavy trucks. The wheel hubs are installed in the wheels of the motor vehicle to support and bear the weight of the wheels as well as the load from the road surface. They provide stable axle support through inner and outer roller bearings, providing anti-friction functions which allow the wheels to rotate smoothly. They also transmit power generated by the engine or electric motor to the wheels, enabling the vehicle to move. In addition, the wheel hubs are combined with the vehicle's suspension system to provide suspension support, alleviate vibrations, and any impacts caused by uneven road surfaces, to provide better ride comfort and stability. The wheel hubs consist of inner and outer rings, inner and outer flanges, tapered rollers, retainers, seals, anti-lock braking system (ABS) sensors, and bolts. You state that the inner and outer flanges, grease, labels, and packaging materials will be sourced in Thailand while other unfinished component parts will be sourced from China. The component parts sourced from China are roughly cut and imported into Thailand without precise measurements and grading necessary for final use in the wheel hubs. Although the inner and outer rings, tapered rollers, retainers, seals, ABS sensors, and bolts will be sourced from China, the critical finishing work for each component part and the sophisticated subassembly and assembly processes will take place at EBI Transmission System (Thailand) Co., LTD in Thailand. The manufacturing process in Thailand begins with the selection of appropriate raw materials. High-carbon chromium steel, such as GCr15, is used due to its high hardness, wear resistance, and fatigue resistance. Blanking is then performed where the round steel from China is cut into billets of specified dimensions by sawing or precision cutting. Afterwards the cut billets undergo forging, CNC rough turning, CNC finishing sequence, drilling, chamfering, tapping, flange splining, raceway grinding ditch and super-precision channel, cleaning, and corrosion prevention. To comply with U.S. motor vehicle and other safety standards, as well as the weight demands of high-performance modern automobiles, the flanges and other component parts of the wheel hub undergo mechanical processing and heat treatment. The outer ring and inner ring grinding is conducted using CNC grinding machines to refine the outer diameter, inner diameter, and end surfaces to an IT5 accuracy level. Raceway grinding follows, achieving Ra 0.2m surface roughness for smooth rolling body contact. The assembly begins with cage mounting, where tapered rollers are fitted with steel or polymer cages like PA66. Sealing ring assembly follows, with double-lip sealing rings installed to prevent contaminants from entering. Pre-lubrication is applied using high-temperature grease (e.g., lithium grease), with a precisely controlled filling amount of ±2%. Press assembly is then carried out, where the inner ring, outer ring, inner and outer flanges, seal, and sensor are hydraulically pressed together to ensure an interference fit. The final step in assembly is the ABS model test, where a sensor verifies the ABS signal to confirm functionality. After that the wheel hubs undergo surface treatment and packaging ready for shipment to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In the instant case, the splining feature gives the wheel hub a functionality beyond a mere bearing. It allows the wheel hub to mesh with the drive axle to transmit torque. As such, we find the outer and inner flanges are the dominant components that impart the character of the double flanged wheel hubs at issue. Since the Chinese rods (bars) are made into flanges and rings in Thailand, and the splining is machined in Thailand, we find that a substantial transformation occurs in Thailand. Therefore, the country of origin of the double flanged wheel hub units with tapered roller bearings, Part Numbers EBH3240 - MOOG: 515096, EBH3241 - MOOG: 515097, and EBH3239 - MOOG: 515058 will be Thailand. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division